Valenzona vs. People

G.R. No. 248584
The Supreme Court acquitted corporate president Valenzona for failing to register subdivision contracts under P.D. 957, ruling prosecution failed to prove his active participation and intent beyond reasonable doubt.
criminal liability corporate officer registration

Case Digest (G.R. No. 248584)

Facts:

The case is Felix G. Valenzona v. The People of the Philippines, G.R. No. 248584, August 30, 2023, Supreme Court Third Division, Caguioa, J., writing for the Court. Petitioner is Felix G. Valenzona (Valenzona); respondent is The People of the Philippines.

In March 2003 ALSGRO Industrial and Development Corporation (ALSGRO), a real estate developer, sold two 100-sq.m. lots to Ricardo B. Porteo under two Contracts to Sell dated March 24, 2003. Porteo paid most of the purchase price but defaulted beginning September 2003; the contracts were rescinded notarially on April 21, 2004. Porteo later discovered the contracts had not been registered with the Register of Deeds and that the lots had been sold to others on July 6, 2004. He demanded refund of his payments; ALSGRO refused. Porteo secured a certification from the Register of Deeds (January 18, 2006) that no contract to sell had been filed and sent letters demanding refund. On January 16, 2008 an Information was filed against Valenzona, then President of ALSGRO, charging violation of Section 17 of Presidential Decree No. 957 (P.D. 957) for failure to register the contracts.

At trial, Valenzona testified that, as President since 1994, his duties were to oversee the business, deal with joint-venture partners and sign documents, but that registration of contracts was performed by ALSGRO’s Marketing, Documentations and Processing Department; he denied personal responsibility for registration. The prosecution established that the subject contracts were not registered within 180 days as required by Section 17 and Section 25 of the Implementing Rules and Regulations (IRR).

Branch 203, Regional Trial Court (RTC), Muntinlupa City convicted Valenzona on May 29, 2014 of violating Section 17, P.D. 957, sentencing him to indeterminate imprisonment (1–2 years) and a P20,000 fine. The RTC rejected Valenzona’s defenses, characterizing P.D. 957 as a special law (mala prohibita) where criminal intent is immaterial and holding that corporate presidents are criminally liable under Section 39.

Valenzona appealed to the Court of Appeals (CA). During the CA proceedings, Valenzona and Porteo executed a compromise settling the civil aspect for P400,000 and Porteo filed an affidavit of desistance; the Office of the Solicitor General (OSG) filed appellee’...(Pro-only)

Issues:

  • Did the Court of Appeals err in affirming the RTC’s conviction of Felix G. Valenzona for violation of Section 17 of P.D. 957 when the prosecution allegedly failed to prove his personal, active participation or volition to cause the non-registration o...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)
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